A NEW PHASE FOR INVESTMENT FUNDS IN LIQUIDATION: INTERIM PAYMENTS AND ORDER OF LIQUIDATION

A NEW PHASE FOR INVESTMENT FUNDS IN LIQUIDATION: INTERIM PAYMENTS AND ORDER OF LIQUIDATION

The Capital Markets Board (“CMB”), in its Bulletin No. 2026/67 dated September 30, 2026, published two new decisions regarding investment funds for which liquidation was ordered by decisions dated September 17, 2026. These decisions supplement the general liquidation principles announced in Bulletin No. 2026/61. They stipulate that interim payments must be made promptly to investors for certain funds, while for others, they specify the order in which the liquidation will be carried out.

1. Interim Payments for the Tera, Pusula, Atlas, and Hedef Funds (64/1775)

The SPK has established an additional liquidation procedure for funds established by the portfolio management companies Tera, Pusula, Atlas, and Hedef. Accordingly, interim payments will be made to all unit holders whose settlements have been finalized, to be offset against the amounts they will be entitled to receive at the conclusion of liquidation. The terms of the interim payment are as follows:

• Calculation Basis: The net investment amount calculated by the Central Depository Corporation Inc. (“MKK”) for each beneficiary will be taken into account.
• Upper limit: Investors whose net investment amount is less than 1 million TL as of the payment date will be paid the full amount. Investors whose net investment amount is 1 million TL or more will be paid a maximum of 1 million TL.
• Priority: The program will begin with money market funds.
• Participation shares: No participation shares will be returned in exchange for the interim payment. Shares will be returned during the final liquidation payments.

The interim payment serves as an advance on the final liquidation payment. The amount paid will be deducted from the amount the investor is due to receive at the conclusion of liquidation.

2. Liquidation Order for A1 Capital, Bulls, and Pardus Funds (64/1770)

No interim payments are provided for funds established by the portfolio management companies A1 Capital, Bulls, and Pardus. Instead, the liquidation process is governed by the following principles:

• Liquidation order: Liquidation will begin with funds whose names include the phrase “money market,” followed by funds in descending order of the number of investors.
• Funds not subject to liquidation: Funds not included in the liquidation but suspended from trading on TEFAS and other distribution channels pursuant to the decisions dated September 17, 2026, may be reopened for trading simultaneously across all distribution channels once the liquidation process is complete. The date of reopening for trading and the trading rules will be determined by the founding portfolio management company. In making this determination, the fund’s portfolio structure, liquidity, market conditions, and investor interests will be taken into account.
• Early reopening option: If necessary to allow liquidation proceedings to be completed, these funds may be reopened for trading without waiting for the liquidation to be finalized.

3. Comparative Overview

4. Assessment

• To benefit from the interim payment, the investor’s subscription agreement must be finalized. Therefore, the status of accounts subject to encumbrances such as pledges, liens, or injunctions must be monitored separately.
• The “net investment amount” will be calculated by the MKK. The Bulletin does not contain detailed provisions regarding the definition of this amount or its relationship to debts to be paid on a priority basis pursuant to Provision A/6 of Bulletin No. 2026/61. It is expected that the application will be clarified through statements by the banks conducting the liquidation and the MKK.
• The payment schedule for investors in the A1 Capital, Bulls, and Pardus funds will depend on the respective fund’s position in the liquidation order. Investors should follow announcements made by the sponsors of these funds regarding the reopening of funds not subject to liquidation.